On paper, Michael Bailey has been the province's most prolific lobbyist, with about 40 active clients as of the middle of May.

But 10 of the clients he was registered to represent have told The Globe and Mail that Mr. Bailey never worked for them or did so a year or more ago.

Lobbying registration documents, which are filed with the province's registrar of lobbyists, are supposed to provide British Columbians with an accurate snapshot of who is trying to influence whom in the government.

Under the Lobbyists Registration Act, it's an offence to knowingly submit false or misleading records to the registrar.

Mr. Bailey declined repeated requests for an interview. But in written statements, he said his firm, Western Policy Consultants Inc., wasn't attempting to mislead anyone, stressing it has always acted in, and supported, the spirit of that act - which is to ensure individuals lobbying government publicly declare their activities.

In some cases, he stated, the firm was unaware of the need to deregister clients it was no longer representing - an "administrative error" that was fixed last week.

In other cases, Mr. Bailey said he registered for clients for whom he did unpaid work or thought might hire him - which isn't required under the act - "out of an abundance of caution."

Moreover, Mr. Bailey pointed out the registrar has specifically advised lobbyists it is "unlikely" there will be penalties for making an honest registration mistake - which he says is what happened.

Meanwhile, the registrar's office is reviewing all of Mr. Bailey's filings to check the information in them.

The Baptist Housing Ministries Society, which operates 15 seniors homes, is typical among the clients contacted by The Globe and Mail.

Mr. Bailey was registered to brief government officials on behalf of the society starting on April 4, 2010, about Vancouver Island's needs for long-term-care funding.

But Baptist Housing spokesperson Deanna Bogart has said her group never hired him - although it and several other denominational organizations did contact a government-relations consultant eight or nine years ago.

Mr. Bailey stated that he registered to represent Baptist Housing after meeting with a consortium of seniors-care homes that were interested in lobbying government. He said he registered the organization to be on the safe side, and then inadvertently failed to take the organization off his client list when that work didn't go ahead.

But a new lobbyist registry computer system adopted last year would have meant Mr. Bailey would have needed to re-register Baptist Housing in 2010 to keep it on the list.

In response, the lobbyist said his secretary did that for all of his past clients because the firm didn't want to be accused of not being forthcoming about its work.

Mr. Bailey was registered to arrange meetings with government for Hollyburn Properties Inc. - which has 44 apartment buildings in Vancouver - to discuss the province's rent-control law and the harmonized sales tax starting May 6, 2011.

But, in an interview, Hollyburn communications director Peter Louwe said he met with Mr. Bailey only once and that the firm isn't even interested in talking to the government about rent control.

For his part, the lobbyist said during that meeting that he mistakenly thought company director Paul Sander wanted to retain him and instructed his assistant to register him.

Deputy registrar of lobbyists Mary Carlson said if her office's verification process finds incorrect information in Mr. Bailey's filings, an investigation may be launched into whether he violated the Lobbyists Registration Act.